Procedure for Response

It is essential to balance the needs of interns with the needs of patients, peer interns, and consortium personnel. The following steps will be taken to address problematic behavior. Depending on the seriousness of the behavioral problems, the process can begin at any level with higher levels being relevant to more serious problems. In cases of violation of the substance use policy of the Pennyroyal Center or WSH (e.g., illegal use, possession or distribution of controlled substances or illegal drugs, or failure of a random drug screen); conviction of a felony or potentially work-related misdemeanor such as theft, substance abuse offenses, or domestic violence; severe violations of the APA Code of Ethics; or when imminent physical or psychological harm to a patient (such as a substantiated incident of patient abuse, or sexual misconduct with a patient) has occurred due to intern actions, termination from the internship and temporary full time employment from the Pennyroyal Center may be immediate.

Verbal Warning.

The intern is provided with a structured verbal warning to delineate the inappropriate behavior and request cessation of the behavior. Verbal warnings are filed only in the evaluation file, and no formal record of the action is kept in the permanent file beyond its effect on overall evaluation scores. Verbal warnings will follow the current format prescribed by the personnel policies of Pennyroyal Center, and will include written acknowledgement to the intern of the following points, in addition to any elements required by current Pennyroyal Center personnel policies:

That the training director and internship director are aware of and concerned about the problem or the performance rating,

That the concern has been brought to the attention of the intern,

That the training director and internship director will work with the intern to rectify the problem or skill deficit, and

That the behaviors associated with the rating are not significant enough to warrant more serious action.

The intern is free to involve the university internship supervisor at any time during the verbal warning process, at the intern’s discretion, but WKPIC will not contact university supervisors for this level of action. The written acknowledgment will be removed from the intern’s file when the intern responds to the concerns and successfully corrects the problematic behavior and completes the internship.

Appeal of Verbal Warning.

Interns may appeal a verbal warning to the internship director and the executive director of the Pennyroyal Center, in writing. After review, the executive director will provide a written response, either confirming the warning or directing the internship director to remove the warning from the intern’s evaluation file. The decision of the executive director is final and not subject to additional appeal.

Written Warning.

A written warning to the intern indicates the need to discontinue an inappropriate action or behavior. The university internship director will be notified of and provided with a copy of written warnings. Written warnings will contain the following components, in addition to any elements required by current Pennyroyal Center personnel policies:

A description of the intern’s unsatisfactory performance or behavior,

Actions needed by the intern to correct the unsatisfactory performance or behavior,

The timeline allowed for correcting the unsatisfactory performance or behavior,

Action to be taken if the unsatisfactory performance or behavior is not corrected,

That the university internship director has been notified and consulted, and

Notification that the intern has the right to request a review of this action.

A copy of this letter will be kept in the intern’s file. Consideration may be given to removing this letter at the end of the internship by the internship director. If the letter is to remain in the file, documentation should contain the position statements of the parties involved in the dispute.

Appeal of Written Warning.

Interns may appeal a written warning to the internship director and the executive director of the Pennyroyal Center, in writing. After review, the executive director will provide a written response, either confirming the written warning or directing the internship director to remove the written warning from the intern’s evaluation file. The decision of the executive director is final and not subject to additional appeal.

Remediation Plan.

For interns, a remediation plan is a time-limited, remediation-oriented, and closely supervised period of training designed to assist the intern in responding to personal reactions or environmental stressors, granted with the expectation that the intern will complete the internship. This period will include more closely scrutinized supervision conducted by the regular supervisor in consultation with the training director, internship director, and university internship director. Remediation plans will contain the following elements, in addition to any elements required by current Pennyroyal Center personnel policies:

Detailed description of the intern’s unsatisfactory performance or behavior, with dated examples.

Specific actions needed by the intern to correct the unsatisfactory performance or behavior, with specific steps to follow to remediate all problems.

The timeline allowed for correcting the unsatisfactory performance or behavior,

Action to be taken if the unsatisfactory performance or behavior is not corrected, up to and including termination of the internship.

That the university internship director has been notified and consulted, and has been provided with a copy of the plan.

The procedures to ascertain whether the problem has been appropriately rectified, including when and how verbal and written feedback on the extent to which corrective actions were or were not successful in addressing the issues of concern will occur.

Several possible and concurrent courses of action may be included in a remediation plan, such as the following:

Increasing the amount of supervision, either with the same or other supervisors,

Requiring contact with the university internship supervisor, and completion of any additional recommended tasks by that supervisor,

Requiring specific academic coursework.

The length of a remediation plan period will be determined by the training director and internship director in consultation with the Human Resources Department of the Pennyroyal Center and the executive director of the Pennyroyal Center. The termination of the remediation plan will be determined, after discussions with the intern, by the internship director and the executive director of Pennyroyal Center.

Appeal of Remediation Plan.

Appeal of Remediation Plan. Interns may appeal the institution of a remediation plan, or any elements therein, in writing, to the internship director and the executive director of the Pennyroyal Center. Interns may include letters or documents from their university internship director in the appeal. After review, the executive director will provide a written response, either confirming the institution of the remediation plan, or its specific elements, or directing the internship director to remove the remediation plan, or any of its specific elements, from the intern’s evaluation file. The decision of the executive director is final and not subject to additional appeal.

Dismissal from the Internship.

Dismissal from WKPIC involves the permanent withdrawal of all agency responsibilities and privileges, and informing the intern’s university training program that the intern will not complete the program. In the event of serious infractions as noted at the beginning of this section, this solution may be used immediately. Otherwise, when specific interventions do not, after a reasonable time period, rectify the problem behavior or concerns and the intern seems unable or unwilling to alter her/his behavior, the training director and internship director will discuss with the university internship director and the executive director of the Pennyroyal Center and the director of Human Resources the need for termination from the training program and dismissal from temporary full time center employment. The training director and internship director will inform the intern in writing and will meet with the intern in conjunction with the executive director of the Pennyroyal Center and a representative(s) of Human Resources, to review the decision. Dismissal decisions are not subject to appeal.

Withdrawal with Voluntary Severance.

If an intern is unable to complete the internship due to physical, mental or emotional illness, or other personal situations not related to ongoing disciplinary action from the internship or academic programwithdrawal from the internship can be arranged with consultation between the internship director and the university internship director, and voluntary severance from temporary full time employment with the Pennyroyal Center. At the discretion of the executive director of the Pennyroyal Center, Administrative Leave with or without pay may be granted in lieu of traditional 14-day notice. Voluntary withdrawal with voluntary severance are not subject to appeal.